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Requirements for Xenon Headlights? (Possible Solution)

Hi There I went through a rabbit hole of reading about Xenon headlights and the ADR regulations for having them installed. As people have been defected by running factory xenon I was researching in ways to make them compliant. Everyone always say needs to be self leveling and have washer installed, which I don't necessarily agree with. For this argument I'm using R34 as reference as I'm more aware on the construction of the headlight compared to the R33 Xenon, which may still be the exact same case. For the self leveling clause taken from ADR 13 - Installation of Lighting and Light Signalling Devices on other than L-Group Vehicles As you can see the bold text "these manually adjustable devices from driver seats" are fine to use. As Series 1 Xenon model headlights do have a 4 level adjuster on the right near the ignition (however not series 2) then these model are consider compliant in that argument. For the Self Cleaning aspect of this argument clause taken from ADR 13 - Installation of Lighting and Light Signalling Devices on other than L-Group Vehicles Now i can understand the argument that Xenon will need a washer as they are over 2000 lumens, but I clicked on the 12 at the end of that sentence and it takes me to the end notes which states R34 for headlight lenses are plastic, not sure if PL is mark as I don't currently have my skyline to confirm that marking is there. But could you not technically get a lenses with the PL marking on it and then get away with the argument that you need a washer. I went through a quick read of the adr and might have missed something else that may cause them to be non-complaint. But wouldn't these technically be complaint headlights Would love to hear other people input on this and shed some light Edit In regard to the the washer portion I might be mistaken ADR 45 (which I believe is Regulation NO.45) states 12 cd (candela) I dont understand that portion in regarding to calculating the candela if anyone can shed some light. Otherwise I guess throw in a washer for the headlight and you definitely comply.